Smeeple Privacy Policy

Smeeple values your trust, and protecting your information is a high priority. Smeeple is committed to your privacy. This Privacy Policy explains what information Smeeple, Inc. and its affiliates (collectively, "Smeeple" or "We") collect, how information is collected, how we use that information, what information is shared with whom, and how Smeeple protects your information when you use our products and services ("Services").

1. When this privacy policy applies

Our Privacy Policy applies to all of the Services offered by Smeeple, and its affiliates, including Services offered on other sites, but excludes Services that have separate privacy policies that do not incorporate this Privacy Policy, and Services that you may receive as a result of your participation in a program that expressly supersedes this Privacy Policy.

Our Privacy Policy does not apply to Services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include Services, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

2. Information we collect

The information Smeeple collects varies based on the type of Services you use and the manner in which you access them. Depending on these factors, Smeeple may collect the following information about you:

Personal Information - This is information that directly or indirectly identifies you, such as your name, email address, or other identifying information about you.
Other Information - Other Information is information that, by itself, does not individually identify you such as browser type, operating system, technical data, and usage. We may link together different types of Other Information or link Other Information to Personal Information.

3. How we collect information

We collect information in the following ways:

Information You Give Us Upon Registration - Many of our Services require you to sign up for an account. When you do, we'll ask for Personal Information like your name, email address, telephone number or credit card.
Information Provided to Us by Your Participation - You provide us information about yourself, such as your name and e-mail address when you register for the Services. In the course of using our Services, you may also volunteer additional information such as location, information about minors, and other information necessary to curate your experience. You can choose not to provide any information that is affirmatively requested of you. However, this may limit your ability to use the Service. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. If you post content (text, images, photographs, messages, comments or any other kind of content that is not your e-mail address) on our Services, the information contained in your posting will be stored in our servers and other users may be able to see it.
Information from Other Sources - We may obtain information about you from affiliates, partners, and other third parties. This information may be used to provide Services to you and to provide analysis about you. We may combine the information we obtain from third parties with information that we have collected about you.
Information We Get from Your Use of Services - We may collect information about the Services that you use and how you use them. This information includes:
- Information You Provide - We may collect information provided by you while using our Services.
- Computer, Tablet, or Mobile Telephone Information - We may collect device-specific information such as your hardware model, operating system version, unique device identifiers, device sensors and mobile network information including phone number. Smeeple may associate your device identifiers or phone number with your account. We will comply with the usage/license restrictions and requirements applicable to the device from which the information comes.
- Log Information - When you use our Services or view content provided by Smeeple, we may automatically collect and store certain information in server logs. This may include: details of how you used our service; Internet protocol address; device event information such as crashes, system activity, hardware settings; browser type, browser language, the date and time of your request and referral URL; and cookies that may uniquely identify your browser or your account.
- Local Storage - We may collect and store information (including Personal Information) locally on your device using mechanisms such as browser web storage (including HTML5) and application data caches.
- Cookies and Anonymous Identifiers - We use various technologies to collect and store information when you visit a Smeeple service, and this may include sending one or more cookies or anonymous identifiers to your device, pursuant to our Cookie Policy. We also use cookies and anonymous identifiers when you interact with Services we offer to our partners, such as Smeeple features that may appear on other sites. See the section "Transparency, Your Privacy Rights, Choices, and Account Termination" below for information about your opt-out choices.

4. Why we use information we collect

To Provide Services To You - We use the information that we collect about you to provide, maintain, protect and improve the Services that Smeeple provides to you.
Analytics - We use analytics tools and other third-party technologies, such as Google Analytics, to collect non-Personal Information in the form of various usage and user metrics when you use our site. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and demographics, and other similar information.
To Improve Our Services - We use de-identified, anonymous information that we collect about you for statistical and analysis purposes to improve our products and services, and to provide statistical analysis.

5. Legal grounds for processing your personal data

We rely on the following legal grounds to process your Personal Information:

Consent - We may use your Personal Information as described in this Privacy Policy subject to your consent. To withdraw your consent for any uses of Personal Information described above, please review the section titled "Privacy Rights, Choices, and Account Termination" or contact us at: support@smeeple.com
Performance of Services - We may need to collect and use your Personal Information to enter into and perform under an agreement with you.
Legitimate Interests - We may use your Personal Information for our legitimate interests, including but not limited to marketing, to provide our Services and to improve our Services and the content on our sites.

6. What information we share

We do not sell your Personal Information to third parties and the information disclosed is the minimum amount necessary to fulfill the legitimate business purpose. We do not share Personal Information with companies, organizations and individuals outside of Smeeple except in the following circumstances:

With Your Consent - We may share your Personal Information with companies, organizations or individuals outside of Smeeple when we have your consent to do so.
Third-Party Service Providers - We may disclose your Personal Information to our third-party service providers who perform various functions on our behalf, but Smeeple requires these third parties to agree in writing to safeguard your Personal Information appropriately and in accordance with the law.
For External Services - We may, from time to time, outsource some or all of the operations of our business to third-party service providers. In such cases, it may be necessary for us to disclose your information to those service providers. In some cases, the service providers may collect information directly from you on our behalf. We restrict how such service providers may access, use and disclose your information. We employ other companies and individuals to perform functions on our behalf. These agents may have access to your information as needed to perform their functions, but they are not permitted to use it for other purposes.
For Legal Reasons - We may disclose any information about you when, in our opinion, such disclosure is necessary to prevent fraud or to comply with any statute, law, rule or regulation of any governmental authority or any order of any court of competent jurisdiction. We will share Personal Information with companies, organizations or individuals outside of Smeeple if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: enforce applicable terms of use/service, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; and protect against harm to the rights, property or safety of Smeeple, our users or the public as required or permitted by law.
In a Transaction - As we continue to develop our business, we might sell, buy or merge with companies, subsidiaries, or business units. In such transactions, data generally are included in the transferred business assets but remains subject to the promises made in any pre-existing privacy statement/policy (unless, of course, the person consents otherwise). Also, in the unlikely event that Smeeple or all of its assets are acquired, your information may be one of the transferred assets.
After Being Fully De-Identified, Incapable of Re-Identification - We may share aggregated, de-identified information publicly and with our partners to evaluate the effectiveness, value, and analytic trends of the Services.

7. How we protect your information

We take steps to secure Personal Information through administrative, technical, and physical safeguards designed to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

8. Transparency, privacy rights and choices, and account termination

Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. Subject to your specific use of the Services, your privacy rights include:

Transparency and the right to information - Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time at support@smeeple.com
Right of access, restriction of processing, erasure - You may contact us to request information about the Personal Information we have collected from you, or to request that your Personal Information be deleted. We will do our best to honor your requests, subject to any legal, ethical and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at: support@smeeple.com. When requesting access to your Personal Information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the Personal Information that we hold about you. You may designate an authorized agent to request information on your behalf, provided that the authorized agent complies with our verification procedures to ensure your permission has been obtained.
Your right to access or delete the Personal Information we hold about you is not absolute - There are instances where applicable law or regulatory requirements allow or require us to refrain from taking certain actions with respect to some or all of the Personal Information that we hold about you. In addition, some or all of the Personal Information may have been destroyed, erased or made anonymous. In the event we cannot provide you with access to your Personal Information, or we are unable to delete it, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Right to correct your information - We endeavor to ensure that Personal Information in our possession is accurate, current and complete. If an individual believes that the Personal Information about him or her is incorrect, incomplete or outdated, he or she may request the revision or correction of that information. We reserve the right not to change any Personal Information we consider accurate. If it is determined that Personal Information is inaccurate, incomplete or outdated, we will use reasonable efforts to revise it and, if necessary, use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may be corrected or updated.
Right to withdraw your consent at any time - When we process your Personal Information based on your consent, you have the right to withdraw that consent at any time. This includes consents regarding your participation in certain Services, email/text/other communication consents, or any other consent that you have provided to Smeeple. You may withdraw your consent by contacting us at: support@smeeple.com. Withdrawing consents may significantly limit your ability to use the Services.
Right to object or opt-out at any time - You have the right to object at any time to receiving marketing or promotional materials from us by either following the opt-out instructions in commercial e-mails or by contacting us, as well as the right to object to any processing of your Personal Information or to participating in any program. We will consider any request you make to us, and provide a reply in a timely manner, according to our legal, ethical and contractual obligations. Some non-marketing communications are not subject to a general right to opt-out, such as communications about transactions and disclosures to comply with legal or ethical requirements.
Right to data portability - You have the right to data portability of your own personal data by contacting us. There are instances where applicable law or regulatory requirements allow or require us to refrain from transmitting your Personal Information to certain recipients or may require additional documentation before transmitting your information. In addition, some or all of the Personal Information may have been destroyed, erased or made anonymous. In the event we cannot fulfill your data portability request or require additional information to do so, we will contact you.

9. Terminating your account

You may terminate your account with us at any time through the account settings or emailing support@smeeple.com Terminating your account will revoke any applicable consents or opt-ins but will be subject to any data retention requirements as described below.

10. Retention of collected information

Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your Personal Information only for as long as we believe it is necessary to fulfill the purposes for which the Personal Information was collected (including for the purpose of meeting any legal, accounting or other reporting requirements or obligations). You may request that we delete the Personal Information about you that we hold, as described above.

11. Accessing and updating your personal information

Whenever you use our Services, we aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your Personal Information, we may ask you to verify your identity before we can act on your request. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Access, correction, or deletion requests can be made by contacting support@smeeple.com.

12. Information on children

The Services are not directed to or intended for use by minors. In compliance with laws, we will not intentionally collect any Personal Information from children under the age of 18. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided us with their Personal Information, please contact us to request that it be deleted.

13. Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy. If we receive a formal written complaint, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that we cannot resolve with our users directly.

14. California user privacy rights

For California residents: We may share your personal information with third parties and affiliated third parties (such as local, state and regional affiliates and affiliate alliances), some of which do not share the We name, for their direct marketing purposes. As these third parties and this category of affiliated third parties are considered an unaffiliated party under California law, you may opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To opt out, please contact us as at support@smeeple.com.

We will continue to provide your information to local, state and regional affiliates and affiliate alliances identified in your membership application or account for the purpose of processing your membership in such affiliate and affiliate alliance programs.

The California Consumer Privacy Act (CCPA), effective January 1, 2020, gives California consumers enhanced rights with respect to their personal information that is collected by businesses. First, California consumers may opt out of having their personal information sold to other persons or parties. Second, they have a right to know:

what specific pieces of information a business has about the consumer;
categories of personal information it has collected about the consumer;
categories of sources from which the personal information is collected;
categories of personal information that the business sold or disclosed for a business purpose about the consumer;
categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.

In addition, California consumers can request that the personal information a business has collected about them be deleted from the business's systems and records. Company may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.

To make a "request to know" or request to delete your personal information, send us an e-mail at support@smeeple.com (Please put either "Request to Know" or "Request to Delete" in the subject heading of your email.) We will use commercially reasonable efforts to honor these requests whether or not you would qualify as a California consumer under the CCPA. If and to the extent we are considered a covered business under the CCPA: We will confirm receipt of your request within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal information within 45 days of receipt of your request but can use an additional 45 days, but we must let you know the additional time is needed.

When contacting us, we may ask you to provide certain, limited personal information, such as your name, email address and/or account login ID and/or password, to verify your request and to match with our records and systems. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months.

Residents of other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at support@smeeple.com.

Pursuant to California's "Shine The Light law (California Civil Code § 1798.983), California residents are entitled, once a year and free of charge, to request the disclosure of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year, if any. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing. You may request this information by contacting us at support@smeeple.com and indicate in the email subject line, "California Shine The Light Request." Please include your mailing address, state of residence and email address with your request.

15. Changes to this privacy policy

This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party. If we change this Privacy Policy, we will post any privacy policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email and/or posting a notice in the Services. Smeeple reserves the right to modify this Privacy Policy at any time, so please review it frequently.

Last modified: August 23^rd, 2023